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Cemex Vernalis Quant'Mining and Reclamation Project Response to Comment B-27 _ Commenter states that the DEIR emission estimates should be based on a reasonable worst-case scenario. CEQA does not require a"worst case"analysis, as stated in the comment. In fact,such a worst case approach was removed from the analogous NEPA regulation many years ago. CEQA requires an analysis of impacts based on what is reasonably foreseeable,which was done. However, the DEIR is based on conservative estimates (meaning the analysis does tend towards a maximum or"worst case" scenario). Response to Comment B-28 Commenter states that because the project will operate 24 hours a day, emission estimates should be based on 24 hour operation not the 8 hour estimates of the DEIR. Due to the variability of operations, most emissions are estimated on an annual basis,assuming maximum permitted production(4 million tons). Response to Comment B-29 Commenter states that the hypothetical production rates on pages 4.6-23— 4.6-24 understate the potential output of this facility and hence all impacts. As discussed above, CEQA does not require a"worst case"analysis based on equipment operating at maximum output, 24 hour per day. Instead, air emissions are based on maximum permitted production,which is 4 million tons. In addition,an analysis at 2.85 million tons was done,as this is the proposed average production level over the life of the quarry. A 1.7 million _ ton production level was analyzed, as this would be the likely minimum annual production. Response to Comment B-30 — Commenter states that the DEIR's operational emissions assume that certain controls are in place that the project is not obligated to actually use (Apex. D,p. 11.). _ Comment refers to the application of water and the 75%control factor. For a discussion of the 75%control measure, see Response to Comment B-33. Dust control measures,including _ adequate watering,are an enforceable measure,under SJVAPCD Regulation VIII.The fabric filter and wet scrubber are reasonable assumptions given the requirement for the plant to incorporate BACT,per SJVAPCD permitting requirements. — Response to Comment B-31 Commenter states that there are other sources of CO emissions, other than those resulting from the increase in traffic generated by the Project, that the DEIR did not disclose that would result in a new, significant impact. — Camel Vermis Quarry Mining and Reclamation Proj 3-12 ESA/203015 Final Ervironmental Impact Rapod June 2008